Under Poland's Act of 24 March 1920, a non-EEA foreigner needs a permit from the Minister of the Interior to buy real estate. A separate apartment is exempt, except in the border zone.
A buyer of a resale home in Poland usually pays 2% PCC, collected by the notary. In Romania the buyer pays no transfer tax; the seller pays 1% or 3%.
Poland taxes the gain at 19% only if you sell within five years from the end of the year of purchase. Romania taxes the price: 3% up to three years, 1% after.
Romania vs Poland property: the short answer
Both countries are in the EU and in Schengen, and both have their own currency. The big difference is the permission rule. In Poland, a buyer from outside the European Economic Area (EEA) and Switzerland needs a permit from the Minister of the Interior to buy a house or land, under the Act of 24 March 1920 on the acquisition of real estate by foreigners. A separate apartment is exempt, except in the border zone. In Romania nobody needs a permit to buy a building, but a non-EU citizen cannot register the land directly in their own name.
On costs, a Polish buyer of a resale home usually pays a 2% civil-law transactions tax (PCC). In Romania the buyer pays no transfer tax. On a new home, Poland applies 8% VAT within size limits, while Romania applies 21%.
In plain words: in Poland an apartment is easy and a house needs a permit; in Romania a house is possible, but the land goes through a structure.
As in our comparisons with Bulgaria and Greece, here are the rules, costs and status side by side.
The big picture
| Romania | Poland | |
|---|---|---|
| EU member since | 2007 | 2004 |
| Schengen | Full member since 1 January 2025 | Since 21 December 2007 |
| Currency | Romanian leu | Polish złoty |
| Permit to buy a home | Not required | Required for non-EEA buyers, except a separate apartment |
| Land for non-EU buyers | Not directly in their own name | Possible with a permit |
Neither country uses the euro, so a buyer with savings in another currency carries an exchange-rate question in both.
Purchase rules for foreigners
Poland: the 1920 Act and the ministry permit
The rule is short. Article 1 of the Act says that a foreigner needs a permit to acquire real estate. The permit is an administrative decision of the minister responsible for internal affairs, provided the Minister of National Defence does not object (and, for farmland, the agriculture minister).
Who is exempt:
- Citizens and businesses of EEA states and Switzerland (Article 8(2)). The transition periods for second homes and farmland ended long ago.
- Any foreigner buying a separate apartment (samodzielny lokal mieszkalny) under the Act on ownership of units (Article 8(1)(1)), and a garage unit linked to the home.
- But not in the border zone. Under Article 8(3), these exemptions do not apply to property in the border zone (strefa nadgraniczna).
For a non-EEA buyer of a house with a plot, the permit is the main step. Under Article 1a, the buyer must show that the purchase is no threat to defence or public order, and must show ties with Poland: for example Polish origin, marriage to a Polish citizen, a residence permit, or business activity in Poland. Land bought for personal needs is capped at 0.5 hectares.
The practical details, from the Act and the Ministry of the Interior:
- Fee: 1,570 złoty stamp duty for the permit, and 98 złoty for a promise of a permit (promesa). The fee is refunded if no permit is issued.
- Validity: the permit is valid for two years; a promesa for one year.
- Time: by law up to two months once the file is complete. The ministry says that in practice it can take two, three or four months, and sometimes longer.
- Without a permit: a purchase made in breach of the Act is void (Article 6).
Romania: the building yes, the land through a structure
In Romania nobody needs a permit to buy an apartment or a house. A citizen of a non-EU state, such as an Israeli without an EU passport, registers the building in their own name. The land is different: under Article 44(2) of the Constitution and Article 6 of Law 312/2005, non-EU citizens acquire land only under an international treaty, on a reciprocity basis. For a villa, the usual routes are a superficies right (superficie) or a Romanian company. We explain both in our guide to land ownership in Romania. With an EU passport, you buy the land directly.
Purchase costs and taxes
| Romania | Poland | |
|---|---|---|
| New home from a developer | 21% VAT | 8% VAT on apartments up to 150 m² and houses up to 300 m²; 23% on the area above |
| Resale home | No transfer tax for the buyer | 2% PCC, paid by the buyer, collected by the notary |
| First home | No special exemption | No PCC on a first home for a buyer who never owned one (Article 9(17) PCC Act) |
| Notary | Official sliding scale (UNNPR), plus VAT | Maximum fees set by a Ministry of Justice regulation, sliding by value |
| Registration | Land register fee of 0.15% for individuals | Court fee of 200 złoty for entering ownership in the land and mortgage register (księga wieczysta) |
Two Polish details: PCC does not apply when the sale is subject to VAT, so a buyer from a developer pays VAT, not both. And a buyer of a sixth apartment or more in the same development pays PCC at 6%, even on a VAT sale (Article 7a).
For the Romanian side, see our full guide to property buying costs in Romania.
In Poland an apartment is easy and a house needs a permit; in Romania a house is possible, but the land goes through a structure.
Ownership costs
Romania: an annual local tax on the building, 0.08% to 0.2% of its taxable value, set by the local council, plus a land tax. The base rose sharply from 2026 under Law 239/2025.
Poland: a municipal property tax (podatek od nieruchomości) per square metre, not per value. The Minister of Finance sets an annual ceiling. For 2026 the maximum is 1.25 złoty per m² of usable area of a residential building, and 0.77 złoty per m² for residential land in the "other" category. Each municipality sets its own rate up to that cap.
Selling tax
The two systems are built differently.
- Romania: a tax on the sale price, not on the gain: 3% if you held the property for up to three years, 1% if longer. The notary collects it on the day of signing. Our guide to tax on selling property in Romania explains the base.
- Poland: 19% income tax on the gain, but only if you sell before five years have passed, counted from the end of the calendar year in which you bought (Articles 10(1)(8) and 30e of the PIT Act). After that, the sale is not taxed. Within five years, the gain is exempt to the extent the money is spent on your own housing needs within three years. The rule covers non-residents too, because income from property located in Poland is taxed in Poland.
Your country of residence may also tax the gain.
Financing for non-residents
Romania: for foreign buyers, financing of up to 70% of the price is possible, with equity of at least 30%. The bank checks income, documents and the property.
Poland: there is no single published rule for non-resident borrowers. Each bank sets its own criteria for income from abroad, the loan currency and the maximum loan. Ask for these three answers in writing before you commit to a property.
Residency
Neither country gives a residence permit for buying a home. Romania has no real-estate route; you need work, business, family, studies or the digital nomad route. See our guide to the residence permit in Romania. Poland's Act on Foreigners lists grounds for temporary residence such as work, business, studies, research and family. Buying property is not one of them. In both countries, a non-EU visitor counts days under the same Schengen rule: up to 90 days in any 180.
Lifestyle: several big cities or one capital region
Poland has several large city markets, among them Warsaw, Kraków, Wrocław and Gdańsk.
Romania's housing market is concentrated around Bucharest–Ilfov. According to the National Institute of Statistics, about 17,300 new dwellings were completed there in 2025, about 29% of the national total. The northern suburbs, near the airport and the international schools, are a market of family homes with gardens.
In both, the first question is the same: an apartment in a city or a house with land? In Poland it decides whether you need a permit; in Romania, how the land is held.
Checklist before you choose
- Your passport. EU or EEA citizen? In both countries most restrictions fall away.
- The type of property. Apartment or house with land? In Poland outside the EEA, a house means a permit and ties to Poland.
- The location. In Poland, the border zone. In Romania, the land register extract.
- The total cost in writing. VAT or PCC, notary, registration, translator.
- The financing. Get the bank's terms for non-residents in writing.
- The exit. Write down the purchase date. It decides the selling tax in both countries.
- An independent lawyer in the country where you buy, who represents only you.
Frequently asked questions
Can a foreigner buy an apartment in Poland without a permit?
Yes, in most cases. Under Article 8(1)(1) of the 1920 Act, buying a separate apartment unit does not require a permit. The exemption does not apply in the border zone, where a non-EEA buyer still needs one.
Do Israelis need a permit to buy a house in Poland?
Yes, unless they hold an EEA or Swiss passport. The permit comes from the Minister of the Interior, costs 1,570 złoty in stamp duty, and requires showing ties with Poland. In Romania no permit is needed for the building, but the land goes through a superficies right or a company.
Is there a transfer tax in Poland and in Romania?
In Poland the buyer of a resale property usually pays 2% PCC; a sale subject to VAT and a first home are exempt. In Romania the buyer pays no transfer tax; the seller pays 1% or 3% of the price.
Does buying property give residency in Poland or Romania?
No. Neither country lists property ownership as a ground for a residence permit.
The bottom line
Poland is simpler for an apartment buyer and harder for a non-EEA buyer who wants a house with land. Romania is the opposite in a way: the house is open to you, but the land needs a legal structure. On costs, Poland charges VAT at a lower rate and a transfer tax on resales; Romania charges no transfer tax to the buyer.
If you are weighing the two, book a half-hour call with me. We will put the property you are looking at in each country into one table: the rules, the full cost and the exit.
Moti Azulay, Compass Group Romania
Sources: Poland, Act of 24 March 1920 on the acquisition of real estate by foreigners, consolidated text Dz.U. 2017 poz. 2278 (Sejm), Articles 1, 1a, 3, 3d, 6, 8 · Poland, Ministry of the Interior and Administration, FAQ on permits · Poland, Stamp Duty Act, Dz.U. 2025 poz. 1154 · Poland, PCC Act, Dz.U. 2026 poz. 191, Articles 2, 4, 7, 7a, 9, 10 · Poland, VAT Act, Dz.U. 2026 poz. 1263, Articles 41 and 146ef · Poland, PIT Act, Dz.U. 2026 poz. 592, Articles 3, 10, 21, 30e · Poland, maximum local tax rates for 2026, M.P. 2025 poz. 726 · Poland, Court Costs Act, Dz.U. 2025 poz. 1228, Article 42 · Poland, Act on Foreigners, Dz.U. 2025 poz. 1079 · Romania, Law 312/2005 (legislatie.just.ro) · Romania, Fiscal Code, Law 227/2015 (legislatie.just.ro) · ANCPI · National Institute of Statistics, Romania (INS)
This article is for general information only and is not legal, tax or financial advice. The rules are current as of 22 October 2026 and change in both countries. Before a transaction, consult an independent lawyer and a tax adviser in the country where you buy.
Now you know more.
This article is general information, not legal, tax or financial advice. Consult local professionals before any transaction.
